Don’t Slash USF Support for Wireless ‘Prematurely,’ CTIA tells FCC
Wireless has already faced deep cuts in universal support and the goal of the FCC now should be to encourage more deployment of mobile broadband, CTIA said in replies on an inquiry and rulemaking on changes to the high-cost universal service program. As a result of the 2008 cap on support for competitive eligible telecom carriers, wireless carriers and other CETCs have already lost $800 million in funding, the group said. The notices follow up on recommendations in the National Broadband Plan that the Universal Service Fund be restructured to pay for broadband.
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"The Commission has correctly recognized that the United States must lead the world in mobile broadband, but it has yet to clarify its long-term vision for how the reforms proposed in this proceeding will advance those goals,” CTIA said. “The proposed Mobility Fund appears far too limited to assure the availability of mobile services everywhere people live, work, and travel, and it is unclear whether the Connect America Fund will support mobile services.”
Wireless ETCs are using USF support to deploy wireless networks in rural America, CTIA said. The FCC should not further reduce funding for CETCs until an alternative funding mechanism is in place, the group said. “The Commission must resist unjustified invitations to slash support for wireless services prematurely,” CTIA said. “Contrary to some commenter claims, there is no evidence that current CETC support levels are unreasonable. Given the tectonic shift in consumer preference toward mobile services, it is not surprising that support to competitive ETCs has grown."
"We're very, very closely aligned with and supportive of the CTIA filing,” Rural Cellular Association President Steve Berry said in an interview Thursday. “You look round and you see wireless paying in twice as much as it gets from USF to begin with,” he said. “I'm not saying all of our [members] are saints, but most of our guys use USF to do exactly what it was intended to do and that is to build towers and provide coverage and new innovative services to those areas that they could not otherwise economically justify.” Berry said he recently toured facilities being built by GCI in Alaska. “We toured some cell sites,” he said. “They would have not been able to build those facilities had it not been for USF."
RCA opposed the FCC’s “tentative approach” in phasing out high-cost support over a 10-year period as USF is transitioned to a broadband program. “First, the phase-down of current support must be accomplished in a technologically and competitively neutral manner,” the group’s reply comment said. “Second, the transition must limit disruptions in the provision of mobile wireless services in rural and high-cost areas.”
Cellular South said its track record demonstrates the importance of USF to rural wireless buildouts. “For a number of years, Cellular South has used federal high-cost support to accelerate infrastructure development in rural Mississippi and Alabama,” the carrier said. “It has demonstrated significant success in increasing the availability of supported services throughout the areas where it has been designated as an eligible telecommunications carrier.”
The FCC should cut high-cost support to conventional services, to free up money for universal broadband deployment, said the National Cable and Telecommunications Association. NCTA said eliminating money for interstate access support, interstate common-line support, and competitive ETC support would allow the FCC to pay for broadband deployment in underserved areas while maintaining the universal high-cost support program at 2010 levels. “High-cost support is meant to benefit consumers, not rural LEC’s,” the association said, “and the reforms proposed by the commission should reflect that.” NCTA also urged the FCC to collect more and better data to ensure that government support for universal broadband deployment goes to the places that need it most.
The FCC needs to cap the high-cost fund at 2010 levels to reduce the burden to contributors and consumers, said Comcast. The first steps are to eliminate interstate access support, interstate common line support and phase out support for CETCs, the cable operator said. Comcast didn’t specifically determine which model the agency should use to allocate universal service subsidies for broadband deployment but said the commission should do a rulemaking to seek further comment.
The FCC must save a “place at the table” for tribal nations when it makes decisions on USF and high-cost program reform, said the National Congress of American Indians and Native Public Media, in a joint reply comment to the FCC. With 80 percent of native communities located in price cap service areas, the groups said it’s critical that the agency preserve current high-cost programs that connect remote rural and tribal communities. The FCC must recognize that by eliminating high-cost support to rural markets it would effectively eliminate the small rural carriers that serve native populations, they said. If the commission truly wishes to improve broadband penetration in tribal areas, it needs to establish an independent tribal broadband fund that would dedicate existing USF funds towards broadband deployment on tribal lands, the groups said. They said the FCC needs to respect the sovereign status of tribes and coordinate any implementation of policy directly through tribal communities and not through states.